Deductibility of the Bank of Spain transfer fee on Treasury bills

The Directorate General of Taxes (DGT) has issued a relevant ruling for individual investors operating with Treasury bills. The central issue revolves around whether the transfer fee accrued in favor of the Bank of Spain can be considered a deductible expense when calculating the return on movable capital obtained.

What the DGT has ruled

The administration has determined that income derived from Treasury bills is classified as returns on movable capital. In this context, the transfer fee applied by the Bank of Spain acts as an accessory expense of the disposal.

The ruling establishes that said fee will reduce the redemption value when determining the return generated upon redemption. For this deduction to be effective, it is necessary that the acquisition and disposal expenses are properly justified in accordance with current regulations.

What it means for you

If you are an individual with investments in Treasury bills, this pronouncement confirms that the transfer cost should not be taxed as net profit, but should instead be subtracted from the gross return. This implies that the return on movable capital subject to IRPF will be lower than the nominal value of the redemption, by considering the fee as a necessary expense to obtain the income.

The application of this criterion is based on the Personal Income Tax Law (LIRPF) and the General Tax Law, allowing accessory expenses to be computable for the quantification of the return.

What you should do

It is fundamental to have the documentation that proves the accrual of the Bank of Spain transfer fee. The correct justification of these expenses is the indispensable requirement for the Administration to accept the reduction of the return in the tax return. It is recommended to verify that the amounts reflected in the redemption settlement match the expenses actually incurred to avoid discrepancies in the determination of the tax base.